SAR Narrative Elements

Mike Deluca, Senior Specialist at FinCEN, shared SAR narrative tips with the audience at ABA's Money Laundering Enforcement conference. Your narrative should include answers to the five "W" words: Who is conducting the act; What is being used; When did it happen; Where did it happen; and Why is it suspicious? Test each SAR narrative against these questions and your report should be most useful. And remember, the answers must be in the narrative. There is no such thing as attachments. Those all get thrown away - and therefore are lost to law enforcement.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 13, 11/05